Introduction

This week, on May 20th, the European Commission released its long-awaited first list of country risk classifications under the EU Deforestation Regulations (EUDR), marking a significant milestone in the regulations implementation. The list - published via an implementing act on the Commission’s Green Forum - ranks each source country as high, standard or low risk for deforestation or forest degradation, in relation to cattle, cocoa, coffee, wood, soy, palm oil and rubber. 

The goal of EUDR risk benchmarking? To reduce administrative burden for low-risk countries, and allow competent authorities to effectively monitor and enforce compliance for those that pose a higher risk. However, the belief that a ‘low-risk’ status lets companies off the hook entirely is misinformed.

In this article we’ll break down the new benchmarking system, and where each country lies. We’ll then outline what these risk benchmarks mean for due diligence, highlight what changes, and what doesn’t.

What are the EUDR country risk benchmarks?

The logic behind the system

Under the EUDR, the European Commission now classifies each producer country into one of three categories: low, standard, or high risk. The country benchmarking system is based on data-driven criteria that are set out in the official EUDR regulation. 

The assessment criteria considers the current rate of deforestation in the country, the rate of expansion of agricultural land for relevant commodities, and production trends of relevant commodities. It supports this assessment with other factors such as local law enforcement, protections for indigenous peoples, and accordance with laws such as the Paris Agreement. This Commission Staff Working Document outlines the principles underlying the  methodology, aiming to ensure transparency, objectivity and consistency.

It’s important to note that the benchmarking list is dynamic. The Commission will review and update countries periodically – with the first review scheduled for 2026 once new global forest data has become available. A dynamic list hopes to incentivise countries to improve the sustainability of their agricultural production systems, minimising deforestation impact as they work towards a low-risk status, whilst simultaneously punishing countries that start to slack. For companies, this means the due diligence workload isn’t set in stone; compliance systems must stay agile and responsive to updated risk information. 

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What changes if your source country is low-risk?

Due Diligence (DD) simplifications - but not a free pass

One of the biggest perks of sourcing from a low-risk country under EUDR is access to a simplified due diligence procedure. The law still requires operators to collect all requisite information about their products and supply chains - this is mandatory regardless of country. 

For each batch of commodity, companies must gather details like the geolocation of the plot, supplier information, and production timeframes. They must also submit a due diligence statement to confirm the product is deforestation-free and legal. None of these basic obligations go away for low-risk production countries.

However, the benefit of sourcing from a low-risk country is that the EUDR does not require formal risk assessments or risk mitigation measures. In other words, companies do not have to actively assess or address deforestation risk when all products come from low-risk countries - unless you receive new information that suggests a problem or a substantiated concern. 

If you do receive a claim suggesting non-compliance with EUDR, then competent authorities must be informed and immediate action taken. The focus for those sourcing from low-risk countries is, as such, information gathering and record keeping, rather than deeper investigations (as the EU has already given them a green light).

Companies must be careful not to get complacent with a low-risk country benchmark - low-risk does not mean no risk. There are concerns that the benchmarking system may encourage circumvention, where products are re-routed through low-risk countries so they may appear to comply with regulation, despite not having fulfilled all the required due diligence. Operators should stay alert to such possibilities, and ensure complete transparency of their supply chain, particularly where mixing of products may occur.

For the complete and official list of country classifications, please refer to the European Commission's Green Forum.

What if you source from standard or high-risk regions?

No change - full due diligence still required

If you are sourcing from countries classified as standard or high risk, the EUDR expects the full due diligence process - general information, risk assessment and risk mitigation. Alongside the standard supply chain information, operators must also assess the risk that the commodities may be linked to deforestation or produced in violations of local laws. Before placing on the market, the risk must be considered ‘negligible’. If you cannot conclude a negligible risk from the risk assessment alone, risk mitigation steps must be taken to reduce the risk to a negligible level. All of these steps must be documented and reflected in your due diligence statement. 

Standard risk countries

For standard risk countries, a risk assessment may entail analysing country-specific factors (e.g., recent deforestation rates, countries forest protection laws, known corruption issues) and substantiate a negligible-risk conclusion with evidence. Many firms choose to use a risk assessment template or software solution to score the risk based upon country, commodity and supplier-specific criteria. If a non-negligible risk is found, the company then must mitigate it: for example, by requiring suppliers to shift to a certified source, conducting independent audits, or even dropping a non-compliant supplier.

High risk countries

For high-risk countries, the full due diligence process is even more stringent. In a high-risk origin country, it is near certain that you will find some level of deforestation risk in your risk assessment, so the mitigation steps become effectively mandatory. These mitigation steps could include third-party audits, use of advanced tools (e.g., satellite monitoring), and collecting extra documentation. They should also have policies, measures and controls in place to manage the risk of non-compliance (chapter 2; article 11). High-risk countries will also face increased auditing by EU authorities; by law, at least 9% of companies sourcing from high-risk countries will be checked annually.

Regulatory checks - vary with risk benchmark

Another factor that the risk benchmark impacts is the compliance checks - an inspection conducted to verify that an operator/trader has fulfilled their legal obligations under the EUDR. These checks will cover at least 9% of the relevant products placed on or exported from the market that originate in high-risk countries, 3% for standard-risk countries, and 1% for low-risk countries. It is important to note the unit being checked is the operator/trader, not the production plot itself, however it may include indirect validation of plot data.

A compliance check focuses on verifying the due diligence of a company. This may include: reviewing the submitted due diligence statement, auditing documentation, checking traceability, verifying claims and inspecting shipments. 

What’s the role of the 1%, 3% and 9% thresholds?

The 1%, 3%, and 9% thresholds are minimum annual inspection rates required of each country, depending on risk. 

Why the first draft is controversial

NGO criticism and industry concern

The first draft of the EUDR country risk benchmarks have not landed without criticism. With only four countries placed on the high-risk list in this first instance – Russia, Belarus, Myanmar and North Korea – there are concerns that it is too limited. These high-risk countries make up a mere 0.07% of the EU’s imports of the regulated commodities, thus leading critics to argue that the benchmarks will let some of the biggest deforestation drivers off the hook. 

Countries well-known for tropical deforestation like Brazil, Indonesia and the Democratic Republic of Congo, have been classified as standard risk. In the eyes of some environmental groups, and many industry professionals, this undermines the credibility of the benchmarking system. 

Mighty Earth, a prominent NGO, blasted the new country classification as “a farce” arguing that some of the “worst levels of deforestation” globally are occurring in places omitted from the high-risk category. 

Allowing countries that are well known for their high deforestation levels off the hook of the heaviest due diligence scrutiny is causing speculation that the EU may have given friendly or strategically important countries an easier pass despite significant deforestation concerns.

New low-risk benchmark?

The low-risk category is not exempt from criticism. On the one hand, Mighty Earth (and others) have challenged the rating of Canada, Ghana, Papua New Guinea and Romania as low risk, calling the decision ‘nonsensical’ - as they claim the benchmark ignores clear evidence of deforestation, forest degradation, and illegal logging linked to commodities from those countries. 

From the industry side, officials in producer countries like Malaysia (standard risk) have complained that the EU “showed favouritism” to itself by giving every EU member state a low-risk label while developing nations are mostly standard risk. 

Adding to the controversy, a group of 11 EU member countries, including Austria, Luxembourg, Italy, and Finland, have called for further modifications to the regulation. In a document reviewed by Reuters, these countries argue that the compliance requirements are overly burdensome, particularly for farmers and foresters. 

They propose introducing a new "very low risk" category, which would exempt certain countries from customs checks and traceability obligations. This proposal aims to simplify compliance for countries with strong forest governance and minimal deforestation risk. While the European Commission defends its process as data-driven, transparent, and fair, it has – at the time this article was published – not yet responded to the latest proposal of a ‘very low risk’ category. 

How to use the benchmarks responsibly

For sourcing teams and compliance leads

Given the political debate, compliance leads may wonder how to actually use the new country risk benchmarks in a responsible way. We suggest treating the risk ratings as one input into a broader due diligence strategy. Below are a few steps to ensure that you remain compliant with the EUDR, regardless of your risk:

• Confirm risk status – don’t assume
  
  • Refer to the European Commission risk benchmark list, to confirm your producer country’s risk status
• Validate the origin of the product - not just the supplier location
  
  • Remember the risk level applies to the country where the product originates from (e.g., where the cocoa for chocolate was grown), not where your direct supplier is based. Supply chains can have multiple steps, so be sure to ensure transparency.
• Track product flow to avoid circumvention
  
  • With different risk benchmarks requiring varying due diligence obligations, there remains a risk of transshipment through low risk countries. Avoid this, and associated fines, by mapping clearly your whole supply chain.
• Document decisions in DDS clearly
  
  • Outline clearly the origin country and risk level of your product, and refer back to these if applying simplified due diligence outputs.

What Coolset does differently

Built-in benchmark logic, always updated

Implementing these changes in your due diligence system might sound daunting, especially for firms managing dozens of suppliers across various countries. This is where technology and automation can make a big difference. Compliance platforms like Coolset are designed to help companies streamline sustainability and due diligence workflows, so you can adapt to the EUDR with confidence.

Here are a few ways Coolset’s tools can support the new EUDR risk benchmarking requirements, alongside any other EUDR changes that come our way:

• Automatic country risk identification
• Integrated risk assessment template
• Dynamic updates and alerts
• Document storage and due diligence
• Collaboration and supplier engagement

For a deeper understanding of EUDR fundamentals, check out our EUDR pillar page which offers a comprehensive introduction to the regulation, and join our EUDR webinar in June. If you’re looking to find out more about how Coolset can help you get ready for EUDR, get in touch here. 

Frequently asked questions (FAQs) on EUDR risk benchmarking

1. What are the EUDR country risk benchmarks?

The EU Deforestation Regulation (EUDR) benchmarks classify producer countries as low, standard, or high risk for deforestation and illegal land use. These categories determine the depth of due diligence required by companies sourcing seven forest-risk commodities: soy, palm oil, wood, cocoa, coffee, rubber, and beef.

2. Which countries are considered high risk under EUDR?

As of May 2025, the European Commission has designated Belarus, Myanmar, North Korea, and Russia as high-risk countries. These countries are also under EU or UN sanctions. The list will evolve as new deforestation data becomes available.

3. What’s the difference between low, standard, and high-risk classifications?

• Low risk: Allows simplified due diligence - no formal risk assessment or mitigation is needed if all product origins are from low-risk areas and no red flags are present.
• Standard risk: Requires full due diligence, including risk assessment and mitigation.

High risk: Requires enhanced due diligence and is subject to the strictest regulatory checks (at least 9% of operators and import volume audited annually).

4. Does a low-risk classification mean no due diligence is needed?

No. Operators must still collect and retain all required supply chain data - including geolocation, supplier identities, and product origin -  and submit a Due Diligence Statement (DDS). Simplified due diligence only exempts companies from risk assessment and mitigation, unless new substantiated concerns arise.

5. How often will EUDR risk benchmarks be updated?

The benchmarking list is dynamic. The Commission will conduct periodic reviews to reflect updated forest data, with the first official revision expected in 2026.

6. What does EUDR require if I source from a standard- or high-risk country?

You must carry out full due diligence, which includes:

• Collecting core supply chain information
• Performing a risk assessment on deforestation and legality
• Implementing risk mitigation measures if any non-negligible risk is found (e.g., supplier switching, audits, certification)
  

7. Where can I check the official country classifications?

Country benchmarks are published on the European Commission’s Green Forum and updated via implementing acts.